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Comments on ICC Draft Environmental Impact Statement

The ICC would produce mixed transportation results at high monetary cost, with enormous adverse environmental impacts and significant adverse community impacts. If it could be built, the ICC would cost almost $1.5 billion, plus huge additional costs for environmental mitigation. Proponents of the ICC vastly overstate its benefits while downplaying its cost, adverse impacts, and legal barriers, including repeated objections by federal agencies.

 

The ICC would increase pressure to build the “Techway” and other segments of the outer beltway. The Board of Trade and other proponents of an outer beltway have made it clear that the ICC is just the first step, with the “Techway” as the next step. The huge additional expenditures involved would buy more sprawl, dirtier air, and more destruction of communities and the environment.

 

The ICC would not reduce average commuting times.  The same Round 2 tests[1] ICC proponents cite for their average speed claims show that average trip times would increase with the ICC. The small increase in average speed simply does not improve average commuting times.

 

The ICC would save little time on most trips, including trips to BWI. For example, building the ICC would save only 6 minutes (7.6%) on the 79-minute trip from Gaithersburg to BWI Airport.  No trip tested in Round 2 showed a greater time saving due to the ICC. And the 65-minute trip from Wheaton CBD to BWI Airport, which might be expected to benefit from the ICC, showed no time savings at all.

 

The ICC would not significantly reduce congestion. The ICC would not reduce the overall average Volume/Capacity (V/C) ratio (a major indicator of road congestion), would not significantly reduce Beltway congestion, and actually would increase the number of miles driven in congested conditions. 

 

On balance, the ICC would increase rather than decrease total traffic on local roads. The DEIS found that building the ICC would increase study area Vehicle Miles Traveled (VMT) on local roads from 7,728,000 to 8,426,000, or nine percent. Regardless of how ICC proponents or the DEIS select and package subsets of the data, the fact that the ICC would increase VMT on local roads by nine percent means the ICC would increase total traffic on local roads. Statements to the contrary are misleading. See note 1.

 

The ICC would increase air pollution, fuel consumption and greenhouse gas emissions. The ICC (and the I-270 widening north of Clarksburg included in testing) would increase countywide vehicle miles traveled (VMT) by 6.7 percent, as well as increasing total vehicle trips. Reduction in VMT is the Measure of Effectiveness the TPR 2 Task Force adopted for improving air quality and is a reasonable (though not perfect) indicator of reduced fuel consumption and greenhouse gas emissions. It is absurd to claim, as some ICC proponents do, that “reducing congestion” would overcome the impact of the additional vehicle miles traveled and vehicle trips the ICC would generate. The Washington region currently fails to comply with federal air quality regulations but has been given a short compliance waiver. Air pollution has significant impacts on human health, including asthma and heart disease. And federal regulations soon will be more stringent than the regulations we currently fail to meet. Failure to meet the current regulations by 2006 or the tighter regulations at some point thereafter would jeopardize most of the region’s federal funding for new transportation projects.

 

The ICC would cause sprawl, not smart growth. Both its location and the fact that it will increase auto dependence mean it would contribute to sprawl, which would in turn further increase reliance on cars. Since the model does not even address this element of induced demand, it overstates the ICC’s benefits and understates its adverse impacts.

 

The importance of transportation’s impact on land use is underscored by the favorable modeling results for the alternate land use. The transit-oriented alternate land use produced uniformly favorable transportation results, including reductions of 4.5-4.6% in total vehicle trips, 4.1-5.2% in vehicle hours traveled, and 6.6-7% in total person travel time by auto. Many transit, walking and biking results improved much more. In contrast, while the ICC increased speeds, it increased vehicle miles traveled (travel demand) by a similar amount and made most transit, walking and biking results worse.

 

The ICC would cause enormous permanent environmental damage to forests, streams, wetlands and parkland. Environmental problems are not limited to the center section of the ICC, but occur along much of the right-of-way. The damage would be particularly acute in the western and center sections, where the ICC would devastate stream valley parks along Mill Creek, the main stem and north branch of Rock Creek, Northwest Branch and Paint Branch. These are among the last best places in Montgomery County in terms of natural beauty, quality and diversity of habitat, and abundance and diversity of species. Federal agencies recognized and commented on the major adverse environmental impacts of the ICC on the Master Plan alignment, as well as the special nature of the places affected.

 

Primarily because of the serious adverse impacts on parkland, federal regulators have indicated repeatedly that they will not approve the ICC on the Master Plan alignment. Although these are not final agency decisions, their reasoning is sound. The agencies are extremely unlikely to reach a different conclusion in a new DEIS or final EIS, and if they did, it probably would be overturned by the courts.

 

Developments after the latest DEIS was completed show the ICC’s adverse impacts would be even greater than the DEIS found. Detailed field work by an expert naturalist working independently from Park and Planning has revealed rare, threatened and endangered species the DEIS overlooked in several areas. Additionally, a recent study by the National Academy of Sciences found that attempts to recreate wetlands generally fail. This underscores the irremediable nature of the ICC’s impact on sensitive wetlands.[2]

 

Construction techniques cannot effectively mitigate the impacts on parkland and other environmental resources. The EPA has already indicated clearly that end-on construction cannot effectively mitigate these impacts.  As the EPA’s regional administrator told Council member Gail Ewing in a September 1997 letter:

 

EPA does not feel this technique would serve as a mitigative measure for the wide variety of long term environmental impacts identified …. For example, once constructed, the highway corridor would fragment large contiguous forest areas[3], adversely impact the stream valley parks, generate potentially polluting storm water runoff in the Paint Branch Watershed, and would be an intrusion into the peace and quiet of the many neighborhoods bisected by the alignment. These impacts would be realized regardless of the construction technique employed[4].

 

Indeed, because elevated highways freeze before at-grade highways, elevated construction would increase runoff problems by increasing the need to use salt or other chemicals.

 

Most of the problems identified by the EPA would remain even if “advanced storm drainage filtration and collection” somehow could address runoff issues. Further, no system exists that could reliably address runoff issues for a major highway through miles of sensitive habitat. In addition to being futile, any attempt to do so would involve costs far in excess of those cited in the DEIS.

 

“Limited tunneling” is utterly unrealistic as a mitigation measure for a highway with such extensive environmental impacts along much of its length. The expense for tunneling a six-lane highway would be prohibitive.

 

Finally, in assessing the relative adverse environmental and community impacts of different potential routes for the ICC, the comparison would not be a mitigated ICC on the Master Plan Alignment versus an unmitigated ICC on alternate routes. Potential mitigation of impacts would have to be applied to all alternatives.

 

The ICC should have been removed from the master plan long ago. The argument that the ICC must be built because it has been on the master plan for a long time is totally circular. The ICC’s environmental problems have been clear since at least 1987, when the first DEIS was released.

 

Maryland should drop the ICC, not pursue alternate ICC routes such as the Northern Alignment studied in the DEIS. Alternate ICC routes have substantial community and environmental impacts and face major political opposition. Even if the stated purpose of going through still another Draft Environmental Impact Statement were to be to obtain approval of the Master Plan alignment, the effect would be to keep all the alternate routes alive.

 

Preparation of a new draft environmental impact statement, and ultimately a final environmental impact statement, would waste years and millions of dollars and would divert attention from options that better balance competing concerns and have a chance of being implemented relatively soon. This is true even assuming the original purpose and need statement could continue to be used and alternate land use patterns still could be excluded from the analysis. We would argue strongly that the original purpose and need statement, which was crafted to justify building a highway, should be modified, and that alternate land use patterns should be considered.

 

ICC opponents have identified viable alternatives to the ICC, both broadly and in the ICC corridor. Judged against the entire range of measures of effectiveness adopted by the Task Force--including auto, transit and walk-bike measures, community and environmental impacts, cost, and safety--the Transit Oriented Scenario outperformed the Road-Oriented Scenario, which contained the ICC and numerous other road and highway projects. The Transit-Oriented Scenario cost over a billion dollars less. It substantially outperformed the Road-Oriented Scenario on transit and walk-bike measures, including mode share, average trip time and accessibility to jobs and housing. It decreased vehicle miles traveled compared to the base case instead of significantly increasing them. It also produced fewer vehicle trips, fewer vehicle hours traveled, and shorter average auto trip times than the Road-Oriented Scenario. It produced far lower adverse community and environmental impacts, as well as superior safety.

 

Within the ICC corridor, widening Muncaster Mill Road to four lanes from Shady Grove Road to MD 28-198 balances cost, transportation, community and environmental concerns much better than building the ICC. This project produces useful transportation benefits at a tiny fraction of the cost of the ICC ($66 million v. a minimum of $1.43 billion) and the environmental impact of the ICC. For example, to the extent increasing countywide average speed is considered useful, Muncaster Mill widening is highly cost-effective. It increases countywide average speed by 1.4 percent.

 

Citizens who filled out questionnaires at Task Force Community Workshops overwhelmingly preferred the Transit-Oriented Scenario, including its approach to East-West connections and land use patterns.

 

We also should reduce the pace of growth (something the TPR Task Force was not permitted to consider) and adopt measures to encourage use of alternatives to driving alone.

 

The ICC is an expensive, environmentally devastating highway to a destination we should not wish on our communities, our county or our children. We must continue to fight it and support better alternatives.

 

For further information, contact Sierra Club Transportation Chair Stephen Caflisch, 301-654-3288.